Privacy and Cookies Policies

Privacy and Cookie Statement, effective as of March 1, 2017

Scalable Software, Inc. (“Scalable”) (“Scalable” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Products and Services as defined below (“Customers”), and individuals who register to download information and resources (“Participants”). This Privacy Statement describes Scalable’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Scalable (the “Products and Services”).

If you choose to provide us with your Personal Information on the Web, we may transfer that Information within Scalable or to Scalable’s third-party service providers, across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Scalable strives to comply with all applicable laws around the globe that are designed to protect your privacy. Although legal requirements may vary from country to country, Scalable intends to adhere to the principles set forth in this Online Privacy Policy even if, in connection with the above, we transfer your Personal Information from your country to countries that may not require an “adequate” level of protection for your Personal Information. In other words, our goal is to provide protection for your Personal Information no matter where that Personal Information is collected, transferred, or retained.

Where the information originates from a country in the European Union, Scalable agrees to comply with all the provisions of the U.S.-EU Safe Harbor Framework and makes an affirmative commitment to adhere to the U.S.-EU Safe Harbor Principles, which can be found at http://export.gov/safeharbor. Where the information originates from Switzerland, Scalable agrees to comply with all the provisions of the U.S.-Swiss Safe Harbor Framework and makes an affirmative commitment to adhere to the U.S.-Swiss Safe Harbor Principles, which can also be found at http://export.gov/safeharbor.

1. Web sites covered

This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including but not limited to http://www.scalable.com (collectively referred to as “Scalable’s Web sites” or “the Company’s Web sites”).

Scalable’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2. Information collected

When expressing an interest in obtaining additional information about the Products and Services or registering to use the Products and Services, Scalable requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Products and Services, Scalable may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Products and Services (“Billing Information”). Scalable may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data About Scalable Customers”, or in the case of Participants, “Data About Scalable Participants”.

As you navigate the Company’s Web site, Scalable may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

3. Use of information collected

The Company uses Data About Scalable Customers to perform the Products and Services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Products and Services.

The Company also may use Data About Scalable Participants to ensure that relevant information is provided Participants, to plan and host corporate events, host online forums and social networks in which event Participants may participate.

The Company may also use Data About Scalable Customers and Data About Scalable Participants for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Products and Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.

Scalable uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data About Scalable Customers and Data About Scalable Participants to provide personalized information about the Company. For additional information about the use of Web Site Navigational Information, please click here.

4. Web Site Navigational Information

Cookies, Web Beacons and IP Addresses. Scalable uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Company’s Web sites and how this information may be used.

Cookies. Scalable uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit the Company’s Web site, Scalable’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Scalable, either by responding to a promotional offer, opening an account, or filling out a Web form, you remain anonymous to the Company.

Scalable uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the Products and Services.

The following sets out how Scalable uses different categories of cookies and your options for managing cookies’ settings:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate the Company’s Web sites and use its features, such as accessing secure areas of the Web sites and using Scalable Products and Services.

Because required cookies are essential to operate the Company’s Web sites and the Products and Services, there is no option to opt out of these cookies.

Performance cookies

These cookies collect information about how Visitors use our Web site, including which pages visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a Visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Company’s Web site functions and performs.

To learn how to opt out of performance cookies using your browser settings click here.

Flash cookies

Scalable uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Web sites to personalize your visit.

To learn how to manage privacy and storage settings for Flash cookies click here.

Functionality cookies

Functionality cookies allow the Company’s Web sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of Scalable’s Products and Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.Scalable may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Web sites to personalize your visit.

To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when visiting Scalable.

Targeting or Advertising cookies

From time-to-time, Scalable engages third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Web site. Scalable sometimes uses cookies delivered by third parties to track the performance of Company advertisements. For example, these cookies remember which browsers have visited the Company’s Web sites. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it.Scalable may also contract with third-party advertising networks that collect IP addresses and other information from Web beacons (see below) on the Company’s Web site, from emails, and on third-party Web sites. Ad networks follow your online activities over time by collecting Web Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other Web sites. This process also helps us manage and track the effectiveness of our marketing efforts.Third parties, with whom the Company partners to provide certain features on our Web site or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

To learn more about these and other advertising networks and their opt out instructions, click here and here.

Web Beacons. Scalable uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web site and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, Scalable may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Scalable uses Web beacons to operate and improve the Company’s Web sites and email communications.

IP Addresses. When you visit Scalable’s Web site, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, Scalable uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

5. Public forums, refer a friend, and customer testimonials

Scalable may provide bulletin boards, blogs, or chat rooms on the Company’s Web site. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Scalable is not responsible for the personal information you choose to submit in these forums.

Scalable may use a referral program. Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Web sites. When using the referral program, the Company requests the friend’s name and email address. Scalable will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. Scalable does not store this information.

Scalable posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Scalable obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Sharing of information collected

Service Providers. Scalable may share Data About Scalable Customers and Data About Scalable Participants with the Company’s contracted service providers so that these service providers can provide services on our behalf. Scalable may also share Data About Scalable Customers with the Company’s service providers to ensure the quality of information provided. Unless described in this Privacy Statement, Scalable does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Business Partners. From time to time, Scalable may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Scalable, the Company may share Data About Scalable Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s). Scalable does not control our business partners’ use of the Data About Scalable Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

Scalable does not share Data About Scalable Participants with business partners unless: (1) you specifically opt in to such sharing via a registration form; or (2) you attend an event and have your attendee badge scanned by a business partner or otherwise provide your contact information. If you do not wish for your information to be shared in this manner, you may choose not to opt in via registration forms and elect not to have your badge scanned at events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.

Billing. Scalable uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

Compelled Disclosure. Scalable reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7. International transfer of information collected

To facilitate Scalable’s global operations, the Company may transfer and access Data About Scalable Customers and Data About Scalable Participants from around the world, including the United States. This Privacy Statement shall apply even if Scalable transfers Data About Scalable Customers or Data About Scalable Participants to other countries.

8. Communications preferences

Scalable offers Visitors, Customers, and Participants who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by emailing privacy@scalable.com or by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to privacy@scalable.com. Customers cannot opt out of receiving transactional emails related to their account with Scalable or the Products and Services.

9. Correcting and updating your information

You may request corrections to and updates to your information by emailing us at privacy@scalable.com. Requests to access, change, or delete your information will be handled within 30 days.

10. Customer Data

Scalable Customers may electronically submit data or information to the Products and Services for hosting and processing purposes (“Customer Data”). Scalable will not review, share, distribute, or reference any such Customer Data except as provided in the Scalable Master Subscription Agreement, or as may be required by law. In accordance with the Scalable Master Subscription Agreement, Scalable may access Customer Data only for the purpose of providing the Products and Services, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, or as may be required by law.

11. Security

Scalable uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. When the Products and Services are accessed using Internet Explorer version 7.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket Layer (.SSL.) technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. Scalable also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web site in a secure server environment that uses firewalls, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. Customers are responsible for maintaining the security and confidentiality of their Scalable usernames and passwords.

Because the Company uses the Products and Services to maintain Data About Scalable Customers and Data About Scalable Participants, this information, which is stored in the Products and Services, is secured in the same manner as described above for Customer Data.

12. Changes to this Privacy Statement

Scalable reserves the right to change this Privacy Statement. Scalable will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

13. Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to privacy@scalable.com or by mailing Scalable:

Scalable’s IT Asset Management Solutions & Services

We provide an integrated, cloud-based, product-set that discovers and aggregates IT asset, usage, license and procurement information, to present coherent and actionable intelligence, supported by industry expertise, to optimize an organizations investment in IT. Our software asset management services have led many businesses to improve. Let your business thrive with solutions and optimization by Scalable.